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Finding 1223510 (2025-002)
Material Weakness 2025
El Paso County
CO
Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303
During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have be...
During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.
View Audit 406864
Finding 1223509 (2025-016)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring § 200.303
None provided.
None provided.
View Audit 406860
Finding 1223508 (2025-015)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Procurement, Suspension & Debarment § 200.214 § 200.319 § 200.320
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that co...
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that contractors were not suspended, debarred, or excluded was not maintained in the files. Management will conduct a review of contracts to ensure required documentation is obtained and properly filed and will update internal policies to include a checklist to ensure compliance prior to contract execution. • Documentation Review: We will conduct a thorough review of our contracts and ensure that all necessary debarment, suspension, or exclusion from receiving or participation in federal awards are obtained and properly filed. • Policy Improvement: We will update our internal policies to include a checklist for all new contracts, which will ensure that documentation related to debarment, suspension, or exclusion is acquired before proceeding. For Items #2, #4, and #5, management concurs with the finding related to Independent Cost Estimate documentation. Management acknowledges that documentation supporting cost estimates was not maintained prior to solicitation. Management will implement a standardized process for documenting Independent Cost Estimates and will conduct periodic reviews to ensure compliance. We acknowledge the lack of documentation on the Independent Cost Estimate (ICE) procedures prior to solicitation. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. Moving forward, we will implement measures to ensure that appropriate documentation is created and maintained for all cost estimates. This includes developing a standardized process for documenting ICE procedures and conducting regular reviews to ensure compliance. For Item #15, management does not concur with the finding. Management states that documentation supporting the Independent Cost Estimate was included in Purchase Order No. PO251039. Management refers to the Small Procurement Abstract/Price Analysis Form, which documents prior pricing information used to support cost reasonableness. Small Procurement Abstract/Price Analysis Form that shows ICE information detailing the last price paid for Consumable Inventory. AMP 2 Response: We acknowledge the need to strengthen monitoring controls to ensure full compliance with applicable procurement, suspension, and debarment requirements. We recognize that verification of contractor eligibility and proper documentation of procurement actions are essential components of an effective internal control system. We acknowledge that documentation of the required suspension and debarment verification was not included in the procurement file at the time of purchase. Although this verification was completed after the fact, we have now confirmed through SAM.gov that the vendors involved were not suspended, debarred, or otherwise excluded from receiving federal funds. To prevent this issue going forward, we have implemented a strengthened control requiring staff to perform and document SAM.gov verification prior to every procurement action, including micro purchases. Verification results will be printed or saved as PDF and filed with each procurement record to ensure full compliance with 2 CFR 200.214 and HUD procurement requirements. These corrective measures will ensure that all future procurements include timely and complete documentation of suspension and debarment checks. Corrective Actions Implemented 1. Suspension & Debarment Verification Controls Strengthened Effective immediately, we have implemented enhanced procedures requiring Housing Administrative Officer personnel to verify all prospective contractors and vendors against the SAM.gov Exclusions Database prior to award. 2. Enforcement of Minimum Solicitation Requirements AMP 2 has reinforced compliance with 5 GCA Chapter 5 and internal procurement SOPs requiring minimum solicitation thresholds: • Three written quotes for small purchases above the micro purchase threshold. • Written justification for any noncompetitive procurement, including emergency, sole source, or inadequate competition. • Staff have been retrained on documentation standards, including price reasonableness, vendor selection rationale, and procurement history requirements. 3. Strengthened Management Oversight and File Review To prevent recurrence, AMP 2 will review all required documentation—including SAM verification, solicitation records, and justifications—is complete. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. These corrective actions strengthen internal controls, ensure proper oversight, and prevent recurrence of the deficiencies identified. AMP 3 Response: For Items #6 (PO251249) and #10 (PO250104), management does not concur with the finding. Management explains that the purchase orders were structured similarly to indefinite delivery/indefinite quantity arrangements to support recurring and variable requirements throughout the fiscal year. Management states that Housing Administrative Officers solicited pricing from multiple qualified vendors at the beginning of the fiscal year to establish competitively awarded pricing schedules. By securing pricing in advance, management was able to address anticipated needs efficiently without preparing separate Independent Cost Estimates for each task, while maintaining fair and reasonable pricing through competition. For Item #22 (BPA250203), management concurs with the finding. Management noted that the blanket purchase agreement was established to support anticipated advertisement services related to the opening and closing of the AMP3 waitlist. At the time, management determined that only one vendor provided hard-copy print publication services locally and was uncertain whether electronic-only media outlets met program needs. Based on this determination, the agreement was executed. However, management acknowledges that the procurement file should have included documentation of market research performed. Management will ensure that future procurement files include adequate documentation of solicitations, market research, and any sole-source or limited-source justifications, as applicable. AMP 4 Response: AMP4 consistently adheres to all procurement policies and requirements prior to executing contracts, agreements, or purchases. Staff will continually ensure documentation is complete and concise with all procurement procedures. AMP4 Response to items: Item #8. We disagree with this finding. Documentation was completed to continue procurement services. See attached documentation labeled as “#8”. Item #s 17, 19, and 20. We disagree with this finding. Documentation on file to support procurement transactions being conducted in a manner that provided for full and open competition. See attached documentation labeled as “#17, #19, #20”. Item # 23. We disagree with this finding. Documentation on file to show evidence services were awarded equally among multiple vendors. See attached documentation labeled as “#23”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027
View Audit 406860
Finding 1223507 (2025-014)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
HUD Housing Programs § 200.303
Finding #2025-014 14.850 Public Housing Operating Fund Eligibility Views of Responsible Officials and Planned Corrective Action AMP 1 Response: We agree that it is essential for responsible personnel to enforce these monitoring controls effectively. Ensuring that staff obtain and properly document a...
Finding #2025-014 14.850 Public Housing Operating Fund Eligibility Views of Responsible Officials and Planned Corrective Action AMP 1 Response: We agree that it is essential for responsible personnel to enforce these monitoring controls effectively. Ensuring that staff obtain and properly document all necessary verification documentation before recertification is crucial for maintaining program integrity. In addition, supervisory personnel will perform periodic reviews to ensure that established procedures are consistently followed. Any deficiencies identified will be promptly corrected. AMP 1 Response to Noted Items • Item #1 - Criminal History/Sex Offender Registry Search We respectfully disagree with this finding. Documentation of the sex offender registry search was performed, verified, and included in the file. The documentation is attached to this response for your review. • Item #4 - EIV Report Timeliness We agree with the finding. The EIV report was processed six and four months late. We acknowledge this issue and will ensure the timely completion of this report. Staff will be reminded of the required timeframes for all certifications. • Item #8 - Declaration of Eligible Immigration Status We respectfully disagree with this finding. Documentation verifying the Head of Household's (HOH) eligible immigration status is included in the file. SAVE verification was conducted and documented at the time of admission to the program. The HOH is the only non-citizen in the household. The relevant documentation is attached for your review. • Item #11 - Independently Calculated Tenant Rent We respectfully disagree with this finding. After reviewing Form HUD-50058, we believe that the correct utility allowance for a 4-bedroom unit is ($498), and the corresponding tenant rent share is $43. These amounts differ from those mentioned in your summary. We have attached the source document for your review and confirmation. AMP 2 Response: We acknowledge the need to reinforce monitoring controls to ensure full compliance with eligibility and verification requirements. Effective immediately, staff will be required to obtain, review, and properly document all mandatory verification materials before completing any recertification of benefits. Recertifications will not be finalized unless the file contains complete and accurate documentation supporting the eligibility determination. In addition, Property Site Managers (PSMs) will conduct periodic quality control reviews to confirm that established procedures are consistently followed and that all required verification activities are fully documented. Any deficiencies identified during these reviews will be corrected promptly and addressed through additional training, procedural reinforcement, or other corrective measures, as appropriate. AMP 2 Responses to Noted Items • Item #5 – EIV Report Timeliness We agree with this finding. The EIV reports used to support income eligibility were processed six and four months late, respectively. We acknowledge this deficiency and will reinforce timeliness requirements with staff to ensure future compliance. Staff will be reminded that EIV reports must be obtained and reviewed within the required timeframe for all annual and interim reexaminations. • Item #7 – Verification of Assets We respectfully disagree with this finding. Documentation verifying household assets was obtained and is included in the file. The source documents supporting asset verification are attached to this response for your review. Based on the documentation on record, the verification requirements were met. • Item #9 – Eligible Immigration Status We also disagree with this finding. Verification of eligible immigration status was completed for the one non citizen Head of Household. The SAVE verification was performed, confirmed, and is attached to this response as supporting documentation. The file contains the required evidence demonstrating eligibility for assistance. • Item #12 – Rent Calculation and Form HUD 50058 We do not agree with this finding. A review of the Form HUD 50058 indicates that the correct utility allowance for a two bedroom unit ($319) was recorded, along with the correct tenant rent share of $239. These amounts differ from those listed in your summary. The source document is attached for your review and confirmation. AMP 3 Response: Management agrees with the need to reinforce monitoring controls among responsible personnel to ensure compliance with eligibility processing requirements for admissions and recertifications. Management will enforce requirements for staff to obtain, review, and properly document all required verification documentation prior to recertification. Furthermore, Property Site Managers (PSMs) will conduct periodic quality control reviews to ensure proper procedures are followed in compliance with HUD requirements. Any identified deficiencies will be promptly corrected and addressed accordingly. AMP 4 Response: We acknowledge the vital need to reinforce internal monitoring controls to ensure full compliance with all eligibility and verification requirements. Enforcing these controls effectively is essential for maintaining program integrity and ensuring the accuracy of benefit determinations. Property Site Managers (PSMs) will conduct regular, periodic quality control reviews to confirm that established procedures are being consistently followed across all files. Any deficiencies or errors identified during PSM reviews will be handled with immediate corrective action. AMP 4 Response to noted items: Sexual Registry Clearance Item #2 and #13. We agree with this finding. Sexual Registry clearance form was not completed by staff. Staff will make corrections to complete Sexual Registry clearance form. Moving forward all intake forms will be verified before finalizing certification. Enterprise Income Verification Item #13. We agree with this finding. Staff oversight on certifying EIV report. Staff will be reminded that all documents requiring PHA staff certification must be completed prior to finalization of certification. Verification of Assets Item #13. We agree with tis finding. Staff failed to obtain third-party bank statement, self-certification, or tenant declaration of asset. Calculated Tenant rent and Utility allowance Item #13. We disagree with this finding. Calculated tenant rent is correct based on income documentation submitted to PHA. Documentation for this finding submitted as attachment “Item 13” Verified Income Item #13. We disagree with this finding. Verified income was calculated and inputted in system. Documentation for this finding submitted as attachment “Item 13 Income”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027
View Audit 406860
Finding 1223506 (2025-013)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Matching / Level of Effort / Earmarking Subrecipient Monitoring
Finding #2025-013 14.267 Continuum of Care GU0011L9C002112, GU0011L9C002213, GU0011L9C002314, GU0037L9C002302, GU0031L9C002203 Matching, Level of Effort, and Earmarking Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management...
Finding #2025-013 14.267 Continuum of Care GU0011L9C002112, GU0011L9C002213, GU0011L9C002314, GU0037L9C002302, GU0031L9C002203 Matching, Level of Effort, and Earmarking Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management has not fully implemented formalized policies and procedures to ensure centralized tracking, periodic reconciliation, and supervisory review of matching contributions in accordance with established control expectations. Responsibilities for monitoring matching activity are decentralized with each planner, and periodic management review of cumulative matching, supporting documentation, and source allowability is not consistently performed. As a result, matching balances may remain interim and not fully supported, increasing the risk of noncompliance with applicable matching, level of effort, and earmarking requirements at each time of reimbursement and not final until grant closeout. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Ongoing effort and as training is made available
View Audit 406860
Finding 1223505 (2025-012)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.318
Finding #2025-012 14.267 Continuum of Care GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management ...
Finding #2025-012 14.267 Continuum of Care GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management would like to clarify that verification of suspension and debarment status was performed through SAM.gov prior to the execution of subrecipient agreements. Historically, the process involved reviewing the entity’s suspension and debarment status directly through SAM.gov, and maintaining an electronic copy of the verification was not established as a standard documentation practice because the information was available for verification through SAM.gov. As changes have occurred to the availability and accessibility of historical SAM.gov records, management recognizes the importance of maintaining independent documentation of the verification performed. While the required verification was conducted, documentation evidencing the verification results was not consistently retained within the applicable procurement or subrecipient files. As a result, management was unable to provide sufficient supporting documentation during the audit to demonstrate completion of the required verification. Corrective Actions: Management will require retention of supporting documentation from SAM.gov verification, including the date of review and evidence of the verification results, within the applicable procurement or subrecipient file. The responsible program personnel will ensure that suspension and debarment verification is completed and documented prior to execution of applicable subrecipient agreements. The applicable procurement and subrecipient files will include SAM.gov verification documentation to support compliance with federal suspension and debarment requirements. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The updated procedures and documentation requirements have been implemented.
View Audit 406860
Finding 1223504 (2025-011)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles
Finding #2025-011 14.267 Continuum of Care Period of Performance Views of Responsible Officials and Planned Corrective Action Management’s Position: Condition 1, 2, & 4 Management concurs with the finding. The questioned cost relates to a payroll charge that was initially assigned to a subsequent Co...
Finding #2025-011 14.267 Continuum of Care Period of Performance Views of Responsible Officials and Planned Corrective Action Management’s Position: Condition 1, 2, & 4 Management concurs with the finding. The questioned cost relates to a payroll charge that was initially assigned to a subsequent CoC Planning Grant during the payroll reimbursement process because funding was available under that grant after the prior funding source had been exhausted. During the drawdown review, management identified that the pay period occurred prior to the start of the grant’s period of performance and therefore was not eligible to be charged to that federal award. Upon identification of the issue, the payroll cost was excluded from the reimbursement request and was not included in a federal drawdown. The appropriate corrective action was to reclassify the expense from the CoC Planning Grant to a local funding source. However, at the time the issue was identified, the accounting staff responsible for overseeing payroll reimbursements and related accounting adjustments were in the process of transitioning responsibilities. As a result, while the ineligible cost was not reimbursed with federal funds, the required accounting reclassification was not completed until the subsequent fiscal year. Corrective Actions: Management has strengthened and formalized its payroll reimbursement review procedures to ensure that grant period-of-performance requirements are verified prior to classification of payroll expenses. Management has also established procedures for documenting and tracking identified exceptions to ensure that required accounting adjustments are completed timely and reviewed by supervisory personnel. The RPE Accounting Department will be responsible for ensuring payroll reimbursement classifications are reviewed for compliance with applicable grant period-of-performance requirements. Accounting personnel responsible for payroll reimbursements and related accounting adjustments will maintain documentation of identified exceptions and ensure required adjustments are completed and reviewed by supervisory personnel. Condition 3 Management does not concur with the finding. Explanation of Disagreement: The Manual Journal Voucher (MJV) referenced by the auditor reflects a reclassification of payroll costs between federal grants. While the payroll expenditure relates to a pay period ending June 14, 2025, the expenditure was not ultimately charged to the grant with a period of performance ending December 31, 2024. The purpose of the MJV was to remove the payroll expenditure from the original grant and reclassify it to the appropriate federal grant. The corresponding entry within the same journal voucher charged the expenditure to a grant whose period of performance encompassed the payroll pay period. As a result, the payroll expenditure was not charged to a federal award outside of its period of performance. Management believes the exception resulted from reviewing only one side of the reclassification entry rather than the complete transaction. The supporting MJV demonstrates that the expenditure was removed from the grant with the expired period of performance and reassigned to the appropriate federal award. Accordingly, management respectfully requests reconsideration of this exception. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Condition 1, 2, & 4 The enhanced payroll reimbursement review procedures and exception tracking procedures have been implemented.
View Audit 406860
Finding 1223503 (2025-010)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Procurement, Suspension & Debarment Special Tests & Provisions HUD Housing Programs
Finding #2025-010 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Wage Rate Determination Views of Responsible Officials and Planned Corrective Action Management’s Position: 1. Purchase Order #241616 – Management concurs with the finding and acknowledges the need to...
Finding #2025-010 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Wage Rate Determination Views of Responsible Officials and Planned Corrective Action Management’s Position: 1. Purchase Order #241616 – Management concurs with the finding and acknowledges the need to strengthen internal controls. 2. Purchase Order #250207 – Management respectfully disagrees with this finding. 3. Purchase Order #250994 – Management respectfully disagrees with this finding. Corrective Actions: Purchase Order # 241616 Management continues to implement improved processes to ensure more consistent compliance monitoring and documentation. This file will be reviewed and corrected as necessary. Management will maintain ongoing monitoring to ensure continuous improvement and sustained compliance. Periodic internal reviews and oversight checkpoints will be conducted throughout the project lifecycle to identify issues early, reinforce accountability, and support timely corrective action where needed. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Management confirms that strengthened internal controls have been implemented to improve oversight, tracking, and compliance monitoring across program activities. These controls include enhanced documentation procedures, defined review and approval processes, and improved coordination among responsible divisions.
View Audit 406860
Finding 1223502 (2025-009)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Special Tests & Provisions Procurement, Suspension & Debarment HUD Housing Programs
Finding #2025-009 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Underwriting Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with the finding of no approved policy effective FY2025. An approved ...
Finding #2025-009 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Underwriting Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with the finding of no approved policy effective FY2025. An approved policy addressing this requirement is in place and was submitted as requested on March 9, 2026. Explanation of Disagreement: The HOME Program has an approved and effective policy that documents underwriting standards used to determine the appropriate amount of homeownership assistance based on a household’s debt, assets, and overall financial resources. Corrective Actions: GHURA Community Development Division continues to working closely with HUD to ensure program compliance and alignment with federal requirements, and is currently in the process of updating and amending its policies to reflect current market conditions and strengthen long-term program sustainability. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Ongoing effort and as training is made available
View Audit 406860
Finding 1223501 (2025-008)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs
Finding #2025-008 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Houisng Quality Standards Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs with the finding and acknowledges the deficiency identified. Correct...
Finding #2025-008 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Houisng Quality Standards Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs with the finding and acknowledges the deficiency identified. Corrective action has been initiated. #2 Disagree, the inspection report was only requested for one of the units, submitted on March 12, 2026. Supporting documentation is available for review for the other units upon request. Explanation of Disagreement: For Item #2, GHURA completed onsite inspections for the two acquisition units reviewed. As these units required no rehabilitation, only one inspection was necessary. The remaining two units are new construction projects currently under development. GHURA has conducted ongoing progress inspections and maintained inspection reports prepared by a third-party inspector throughout the construction process. Units are scheduled to be completed 2nd quarter FY2027 at which time the final inspections will be conducted to ensure compliance with program requirements. Corrective Actions: Item #1 - Guam initiated HOME rental monitoring and technical assistance for the three rental developments currently within their compliance periods. Consistent with the schedule provided to HUD by GHURA, RPE conducted entrance meetings with the Subrecipient organization’s deputy director and key staff on June 17, 2026. The Subrecipient was notified of physical inspections scheduled for June 22, 23, and 25, 2026, to be conducted by GHURA AE. One complex, containing more than ten (10) HOME-assisted units, will also undergo financial viability monitoring. File reviews, interviews, and document collection are currently underway. Item #1 – RP&E has initiated this action and will continue as required moving forward. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Item #1 - The monitoring process will conclude within 30 days of the entrance meeting, on July 17, 2026, at which time a letter outlining the monitoring results will be issued.
View Audit 406860
Finding 1223500 (2025-007)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Eligibility Subrecipient Monitoring HUD Housing Programs
Finding #2025-007 14.239 HOME Investment Partnerships (HOME) Program Eligibility Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs and acknowledges that approving the matter without a more thorough evaluation was an oversight. #2 Management dis...
Finding #2025-007 14.239 HOME Investment Partnerships (HOME) Program Eligibility Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs and acknowledges that approving the matter without a more thorough evaluation was an oversight. #2 Management disagrees. HOME maximum subsidy per 3-bedroom unit is $338,419.00. Total HOME investment is $112,500.00. Corrective Actions: Corrective actions include strengthening internal controls and oversight. Management will implement a more comprehensive review process moving forward. This process will include additional supervisory review, verification of supporting documentation, confirmation of regulatory and policy compliance, and consultation with appropriate program and legal staff, when necessary, before approvals are granted. Management will also establish review checklists and documentation standards to ensure that all relevant factors are consistently evaluated and adequately documented. Moving forward, the Community Development Division will undergo a more rigorous evaluation process standardized review checklists and documentation requirements will be implemented to promote consistency, accountability, and proper recordkeeping. Management will monitor compliance with these enhanced procedures to reduce the risk of future deficiencies, oversights and ensure approvals are supported by adequate due diligence. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Final approval checklists will be implemented by August 1, 2026.
View Audit 406860
Finding 1223499 (2025-006)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Special Tests & Provisions HUD Housing Programs Internal Control / Segregation of Duties
Finding #2025-006 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Special Tests and Provisions - Rehabilitation Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with...
Finding #2025-006 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Special Tests and Provisions - Rehabilitation Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that documentation can be strengthened. However, management does not concur that controls for project documentation and assigned personnel are absent. Explanation of Disagreement: Pre-rehabilitation inspections are conducted by GHURA engineering personnel for all proposed acquisitions. The assessment process requires multiple visits while personnel build the details to develop the scope of the necessary rehab work. These assessments lead to the work writeups to address identified deficiencies (safety, structural, electrical, plumbing, HVAC, lead, radon, etcetera). Senior engineering personnel oversee this process from initial assessment to final writeup. Corrective Actions: Management will reassess current procedures and documentation of pre-rehab condition. This will include inclusion of a periodic review of these procedures. The purpose of this assessment is to augment compliance with rehab requirements and coordination between key divisions responsible for activity completion. The A&E Division will remain responsible for the rehabilitation of CDBG-funded activities and to maintain appropriate documentation. The RPE Division will remain responsible for coordinating and ensuring compliance with CDBG requirements for the rehabilitation of funded activities and to maintain appropriate documentation. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The enhanced documentation procedures will be implemented by or before the beginning of the next program year cycle.
View Audit 406860
Finding 1223498 (2025-005)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Subrecipient Monitoring HUD Housing Programs Reporting
Finding #2025-005 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Reporting - Federal Funding Accountability and Transparency Act Views of Responsible Officials and Planned Corrective Action Management’s Position: Ma...
Finding #2025-005 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Reporting - Federal Funding Accountability and Transparency Act Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that documenting FFATA lagged in some instances during the earlier periods reviewed. In some instances, challenges with the reporting system complicated our ability to submit timely reports. This was discussed with the audit team. A review of additional requests by the auditor was not completed in time to be incorporated into this commentary. Explanation of Disagreement: FFATA submissions in FSRS are often complicated by limitations in the reporting system. For example, validation of an awardee’s address was often an impediment to completing the FFATA submission. The result is the inability to complete the reporting process. Responsible staff would make multiple varied attempts to enter verified information that would be rejected. In an effort to comply, responsible staff make attempts to resolve this either through the funder or the reporting system. Corrective Actions: To strengthen FFATA reporting, management will review its established processes of pre-award through award documentation. Management will review assigned responsibilities to ensure confirmation of FFATA submission. The RPE Division is responsible for FFATA reporting into SAM.gov. Specific responsibilities to oversee this process are assigned and necessary accesses assigned. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Immediate. The processes of FFATA reporting are in place for all FFTA submissions. Personnel are assigned to ensure the FFTA process is executed and documented for all funded activities.
View Audit 406860
Finding 1223497 (2025-004)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
Reporting Subrecipient Monitoring HUD Housing Programs
Finding #2025-004 14.225 CDBG – Endtitlement Grants Cluster B23ST660001, COVID-19 B20SW660001, B20ST660001 Reporting - CDBG Financial Summary Report Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowled...
Finding #2025-004 14.225 CDBG – Endtitlement Grants Cluster B23ST660001, COVID-19 B20SW660001, B20ST660001 Reporting - CDBG Financial Summary Report Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that supporting documentation explaining differences between the PR26 – CDBG Financial Summary Report, PR26 – CDBG-CV Financial Summary Report, and the Authority’s accounting records can be further strengthened. However, management does not concur that the identified differences resulted in noncompliance with CDBG expenditure requirements or applicable Public Service (PS) and Planning and Administration (PA) expenditure limitations. Explanation of Disagreement: Management notes that the PR26 report referenced in the finding is not the final CDBG Financial Summary Report submitted for Program Year 2024. Management requests that the PR26 report submitted in response to audit request #204 be considered for purposes of evaluating the reported CDBG financial activity. Management also notes that the FY2025 expense detail does not represent the full amount of CDBG expenditures reflected in FY2025 draw activity. This is because certain payroll expenditures incurred during FY2024 were drawn during FY2025 and are therefore included in FY2025 cash activity reported through HUD. Management notes that the purpose of the PR26 reports is to summarize CDBG and CDBG-CV financial activity and demonstrate compliance with applicable program expenditure limitations, including the Public Service and Planning and Administration caps. Management has reviewed these calculations and confirmed, in coordination with HUD representatives, that the applicable caps were not exceeded. Management further notes that differences between the PR26 reports and the Authority’s accounting records may occur due to differences in reporting methodologies. The PR26 reports are prepared based on cash activity reported through HUD, while the Authority’s financial records are maintained on an accrual basis. As a result, differences may occur due to timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. Based on the above, management maintains that the identified differences are attributable to reporting basis and timing differences rather than noncompliance with CDBG expenditure requirements. The final CDBG Financial Summary Reports and supporting documentation have been provided for the auditor’s consideration. Corrective Actions: Management will enhance existing PR26 preparation procedures by maintaining supporting documentation identifying significant reconciling items between HUD-reported activity and the Authority’s accounting records. The purpose of this documentation will be to explain differences resulting from reporting methodology, timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. The RPE Accounting Department, will be responsible for maintaining supporting documentation for PR26 reporting and documenting significant reconciling items. Supervisory review will continue to be performed prior to submission of future PR26 reports to ensure reported information is supported and appropriately documented. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The enhanced documentation procedures will be implemented beginning with the next PR26 reporting cycle.
View Audit 406860
Finding 1223496 (2025-003)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
HUD Housing Programs Special Tests & Provisions
Finding #2025-003 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions – Reasonable Rent Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed the regulations 24 ...
Finding #2025-003 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions – Reasonable Rent Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed the regulations 24 CFR 982.507 and is fully knowledgeable of the process when determining rent reasonableness with comparable units in the private market and properly document all comparables. Before executing a HAP Contract, a rent reasonableness analysis is conducted for all units. This analysis includes assessing comparable unassisted units taking into account the location, size, type, and age of unit, as well as any amenities (such as septic, sewer, air conditioning, etc.), and utility responsibilities. We have standard operating procedures and methodologies in place to conduct these analyses and certify that comparable rents are reasonable. Any identified errors are likely due to isolated oversights during the data entry process. Explanation of Disagreement: Listed below are the discrepancies with accompanying comments. Out of the seven (7) entries provided, one (1) was identified as a calculation error. TOTAL: 07 entries (table provided to support explanation) 1. 4 Rent Reasonableness entries were completed correctly. 2. 2 Rent Reasonableness entries were system input errors. 3. 1 Rent Reasonableness analysis was an administrative error. Voucher Number Effective Date Auditor Comment Section 8 HCV Response HCV2828 2/1/2025 Per examination of the Rent Reasonableness reports, it was noted the comparables are not within similar area locations. We noted that the unit is located in Yigo (Northern), while the comparable units used in the rent reasonableness determination were located in the Southern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,924, which is less than the initial calculated average of $2,966.67. SYSTEM INPUT ERROR: Location of the Proposed Unit was inputted as 'Southern' when the Yigo unit is a 'Northern' located unit. As a result, comparables for units located in the southern location were pulled. SOLUTION: All Section 8 assisted units in the system will be assessed to verify location accuracy based off of village and zip code. NED0444 10/1/2024 The Authority did not rely on the comparable contract rents reflected in the Rent Reasonableness Determination Report (average $949.33), but instead recalculated contract rent using gross rent less a utility allowance, resulting in $1,000. This methodology is not directly supported by the market comparables presented in the report. ADMINISTRATIVE ERROR: The amount of $949.33 should have been the contract rent amount. SOLUTION: Review discrepancy with team to ensure errors will not happen in the future. HCV2796 1/1/2025 Per Mark McCormick on the Rent Reasonable Determination Report and Request for Tenancy Approval (RFTA), the documents indicate no comparable unassisted units were available in the proposed unit's area; however, a nearby unassisted unit in the RFTA is at Ladera Tower and appears reasonably comparable based on proximity. 12a. Owner’s Certification 1. Ladera Towers - Date rented: 9/1/24 - Rental amount: 2,450 2. Washington Dr - Date rented: 10/21/21 - Rental amount: 1,850 3. Quichocho St Villa - Date rented: 1/21/23 - Rental amount: 1,850 RR DETERMINED CORRECTLY: (1) Rent Determination Documents has a note that the unassisted units are not on premises. (2) The units listed in the RFTA-12A were not located on the premises of the unit to be under HAP contract which is why it was not referenced. (3) The Ladera Towers may or may not be in the unassisted units database; is was not in the database at the time the comparables were made. HCV2876 6/30/2025 The approved contract rent of $1,400 was calculated using the average column in the Rent Reasonableness Determination Report (exception); however, the three comparable unassisted units listed on the RFTA are each $1,200, which is lower than the approved amount. Owners Certification: 138 (#347) and 148 (#363) Chalan totche $1,200 132 Chalan Guihan #402 $1,200 RR DETERMINED CORRECTLY: RFTA lists LITHC properties. LITHC unit rates are not used in comparables. 6-05-0050- 56262 9/1/2025 The owner proposed rent of $2,500 was determined to be rent reasonable based on the average comparable unassisted units of $3,774 and Fair Market value of $2,964. However, it was noted that the unit is located in Chalan Pago (Central), while one of the comparable units used in the rent reasonableness determination was located in the Northern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,870, which is less than the initial calculated average of $3,774. SYSTEM INPUT ERROR: Location of unassisted unit was labelled as 'Central' when the village and zip code indicates that unit is located in the 'Northern' area. SOLUTION: All Section 8 unassisted units in the system will be assessed to verify location accuracy based off of village and zip code. 6-08-0353- 60378 1/1/2025 Per examination of the rent determination report, we noted the approved rent exceeds the rent reflected in the owner-certified lease for a comparable unit; however, no documentation was provided to support or justify the variance between the approved and contracted rent amounts. RR DETERMINED CORRECTLY: Tenant exercised the rent burden rule for this contract. The $100 amount does not exceed the tenant's 40% of AMI. NED0070 11/1/2024 Rent determination documentation indicates an approved amount of $940; however, the executed lease agreement (dated 10/29/2024) reflects a rent of $942 as requested by the landlord. No supporting documentation was provided to justify the variance between the approved rent and the amount charged. RR DETERMINED CORRECTLY: Approved amount for the contract was $942; which aligns with landlord's request. Corrective Actions: (1) SYSTEM INPUT ERRORS: All Section 8 unassisted and assisted units in the system will be assessed to verify location accuracy based off of village and zip code. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. Preventive Measures: Closely assess rent determination calculations to ensure accuracy and certified rental amounts are correct. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Timeline for Resolution: (1) SYSTEM INPUT ERRORS: • 6/18/2026: Request report from MIS to provide list of units with location in the systems. • 6/22/2026: Received report from MIS, consisting of 4,922 units. • 6/22-6/10/2026: Review report, identify deficiencies, and create plan to correct deficiencies. • 6/13/2026: Assign staff to update system with accurate data to address any location deficiencies. • 7/31/2026: Complete assignment. Preventive Measures: Pull quarterly report for assisted and unassisted units in the system and review list of units and ensure location is accurate based off of village and zip code of unit. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. • 6/17/2026: Review and discuss discrepancy with HCV Inspection Supervisor • 6/18/2026: Conduct Inspection Team Meeting to address discrepancy with HCV Inspection Team to identify the cause of the issue. Review SOP with team to ensure similar errors do not happen in the future • 6/18/2026: Assignment completed.
View Audit 406860
Finding 1223495 (2025-002)
Material Weakness 2025
Guam Housing and Urban Renewal Authority
GU
HUD Housing Programs
Finding #2025-002 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions - National Standards for the Physical Inspection of Real Estate (NSPIRE)/Housing Quality Standards Inspection Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respect...
Finding #2025-002 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions - National Standards for the Physical Inspection of Real Estate (NSPIRE)/Housing Quality Standards Inspection Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed to our biennial inspection requirements and are fully compliant with all applicable regulations. When a unit fails inspection, we work quickly to resolve the issues and ensure housing standards are met, as outlined in 24 CFR Part 982. In accordance with 24 CFR 982.405(d), we provide both participants and landlords adequate time to correct deficiencies, which is documented in our system. We remain compliant in our conduct and oversight of these requirements. Should there be a late HQS biennial inspection, this should not interrupt the HAP. Suspending these payments creates an undue burden for participants and strains our partnership with landlords. Unless a unit is deemed unsafe, HAP will continue. HAP abatement and reimbursement policies are in place should they need to be activated to retrieve HAP in instances where it was not entitled. Explanation of Disagreement: The list provided below is insufficient to claim any finding in HQS due to the following: TOTAL: 32 entries (table provided to support explanation) 17 families ended their participation before the biennial inspection was due. 5 families were port-out participants before the biennial inspection was due. 5 units were recorded to have inspections completed before the biennial inspection due date and passed inspection. 1 unit inspection was completed on time, but failed on the first inspection. 1 unit inspection was completed on time, but was a no entry on the first attempted inspection. 1 family moved out of the unit before the biennial inspection. 1 family had incorrect dates in this list and was recorded to have met the biennial inspection and passed inspection. 1 family’s inspection was late by 17 days, however, the inspection was completed and passed in that same month, which did not affect the HAP. Voucher Latest HQS Inspection Activity Sum of Amount Section 8 HCV Response 6-01-0105-926 09/28/23 $ 220.00 EOP: 1/31/25 6-01-0212-58183 04/13/23 $ 13,824.00 EOP: 3/31/25 6-03-0198-2327 4/4/2022 (should be 9/19/22) $ 27,648.00 NOTE: Latest HQS Inspection Activity is 9/19/22 and inspection passed on 9/11/24. The 4/4/22 Inspection Date is for Voucher #6-04-0171-47367 (different tenant). 6-05-0005-42278 07/12/22 $ 25,320.00 NO ENTRY: 7/9/24 | PASSED: 8/21/24 6-05-0145-47900 07/18/22 $ 12,794.00 PASSED: 7/9/24 6-05-0241-46089 08/29/23 $ 2,280.00 OUTSEARCHING: 4/1/25 6-07-0028-2139 07/19/22 $ 23,996.00 FAILED: 7/17/24 | PASSED: 8/19/24 6-07-0115-1927 09/11/23 $ 6,278.00 EOP: 2/28/25 6-07-0289-52502 05/06/22 $ 28,316.00 PASSED: 5/6/24 EHV0132 08/23/23 $ 1,076.00 PORT-OUT: 10/31/24 FUP0156 08/21/23 $ 17,607.00 EOP: 5/31/2025 HCV0134 01/05/22 $ (402.65) PORT-OUT: 6/30/22 HCV0521 04/22/22 $ 18,997.00 PASSED: 4/3/24 HCV0561 08/16/23 $ 14,409.00 EOP: 6/30/25 HCV0735 12/09/22 $ 1,227.00 EOP: 11/30/24 HCV0874 04/17/23 $ 4,383.00 EOP: 12/31/24 HCV1038 03/17/22 $ 5,130.00 PASSED: 1/17/24 HCV1083 9/12/2022 (should be 2/15/22) $ 17,987.00 PASSED: 1/17/24 HCV1333 08/17/23 $ 4,686.00 EOP: 12/31/24 HCV1699 10/18/22 $ (90.40) PORT-OUT: 8/10/23 HCV1704 09/12/23 $ 5,596.00 EOP: 1/31/25 HCV1811 08/31/23 $ 9,096.00 EOP: 3/31/25 HCV1873 07/11/23 $ 1,096.00 EOP: 11/30/24 HCV2024 07/06/22 $ 22,875.00 PASSED: 7/23/24 (LATE) HCV2110 07/19/23 $ 8,344.00 PORT-OUT: 4/30/25 HCV2452 08/02/23 $ 6,256.00 EOP: 1/31/25 HCV2457 07/13/23 $ (1,681.00) PORT-OUT: 7/5/24 HCV2466 08/31/23 $ 1,374.00 EOP: 6/30/25 MS0028 04/05/23 $ 1,449.00 EOP: 10/31/24 MS0031 04/14/23 $ 1,026.00 EOP: 4/30/25 NED0213 07/11/23 $ 9,642.00 EOP: 3/31/25 VASH0149 08/03/23 $ 6,272.00 EOP: 7/31/25 Corrective Actions: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001.
View Audit 406860
Finding 1223494 (2025-002)
Material Weakness 2025
DAUPHIN COUNTY CONSERVATION DISTRICT
PA
Reporting Internal Control / Segregation of Duties
Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should establishe procedures to ensure reports are reviewed and approved prior to submission in the state's GIS system. Action: The Financial Coordinator will prepare the quarterly report and related supporting documenta...
Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should establishe procedures to ensure reports are reviewed and approved prior to submission in the state's GIS system. Action: The Financial Coordinator will prepare the quarterly report and related supporting documentation and enter the data into the state's GIS system. A draft of the quarterly GIS report and supporting documentation will be fowarded to the District Manager for review and approval. The manager approved report will be submitted in the state's GIS system by the Financial Coordinator for final review and approval by the state. Date for Completion: June 16, 2026.
View Audit 406857
Finding 1223493 (2025-001)
Material Weakness 2025
DAUPHIN COUNTY CONSERVATION DISTRICT
PA
Procurement, Suspension & Debarment
Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should design and implement procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract. Action: District staff will perform a verification of suspension or debarment prior ...
Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should design and implement procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract. Action: District staff will perform a verification of suspension or debarment prior to entering into future contracts by checking the System for Award Management Exclusions and saving a screenshot showing the results of the search. Date for Completion: June 16, 2026.
View Audit 406857
Finding 1223482 (2025-003)
Material Weakness 2025
Spirit Lake Community School District
IA
Internal Control / Segregation of Duties
SEE RESPONSE AND CORRECTIVE ACTION PLAN AT 2025-001
SEE RESPONSE AND CORRECTIVE ACTION PLAN AT 2025-001
View Audit 406845
Finding 1223479 (2025-003)
Material Weakness 2025
Evergreen Rural Water of Washington
WA
Allowable Costs / Cost Principles § 200.303 § 200.414
Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate app...
Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate appropriate internal controls over indirect cost calculations; ensure the performer of the internal control has the required knowledge & understanding of compliance requirements & accounting to catch errors during the review & approval process. There is no disagreement with this audit finding. Action taken in response to finding: In January 2026 we recevied an email from DOL outlining the correct way to allocate indirect costs. We made those adjustments to our indirect calculations and will adjust any previous overstated reimbursements. Name(s) of the contact person(s) responsible for corrective action: Tracey Hunter. Planned completion date for corrective action plan: May 2026
View Audit 406840
Finding 1223470 (2025-003)
Material Weakness 2025
COUNTY OF POCAHONTAS
IA
Subrecipient Monitoring Reporting Internal Control / Segregation of Duties
The County will develop procedures to ensure that required federal reports will be reviewed and approved by an independent person who is knowledgeable about the program. Indpendent review will be documented.
The County will develop procedures to ensure that required federal reports will be reviewed and approved by an independent person who is knowledgeable about the program. Indpendent review will be documented.
View Audit 406835
Finding 1223469 (2025-003)
Material Weakness 2025
Campbellsport School District
WI
Reporting
District has implemented procedures where amounts reported on the SBS Quarterly and Annual reporting are tied out directly to financial system reports. The business manager and Assistant Superintendent of Teaching & Learning will both review the amounts included in the filings.
District has implemented procedures where amounts reported on the SBS Quarterly and Annual reporting are tied out directly to financial system reports. The business manager and Assistant Superintendent of Teaching & Learning will both review the amounts included in the filings.
View Audit 406824
Finding 1223462 (2025-002)
Material Weakness 2025
City of Greeley
CO
Reporting § 200.502 § 200.510
Condition: The Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: The Finan...
Condition: The Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: The Finance Department recently hired a new Grants Manager after being without this critical position for almost a year. The Grants Manager, along with the Grant Specialist and the Financial Reporting team accountants, plan to work together to improve the tracking and reconciliation of grant activity. In addition, the City implemented eCivis Euna Grants, a grant application, tracking, and reporting system, in November of 2025. The Grants Team will be working with Departments to document the grants process formally for the City and this will ensure that all grants are accounted for and tracked in the Euna grants system. This renewed capacity and new initaitives, supported by the new administrative cost recovery framework and the City's grants management platform, reflects a broader commitment to managing external funding with the same discipline applied to locally generated revenues. Contact person responsible for corrective action: Julie Cunningham, Grants Manager. Anticipated Completion date: 05/01/2027
View Audit 406819
Finding 1223459 (2025-003)
Material Weakness 2025
Corbett School District
OR
Reporting Subrecipient Monitoring § 200.510
Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), ...
Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), the auditee must prepare a complete and accurate Schedule of Federal Expenditures (SEFA) for the period covered by the auditee’s financial statements and submit it with the reporting package by the date required by auditors. The SEFA must include total federal awards expended by Assistance Listing (ALN, formerly CFDA), pass-through entity identifying numbers as applicable, the amount provided to subrecipients (if any), and other required disclosures. The SEFA must include all federal expenditures and awards for the year reported and be reconciled to the General Ledger. Condition: The District did not timely prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). The SEFA provided for audit did not reconcile to the District’s general ledger and contained multiple inaccuracies, including reporting federal expenditures in excess of current-year general ledger activity and misclassification of awards, with certain state programs incorrectly reported as federal programs. Cause: The District lacked effective internal controls over the preparation and review of the Schedule of Expenditures of Federal Awards. Specifically, expenditures reported on the SEFA were not reconciled to the District’s general ledger, and there was no documented review process to verify program classification or reported amounts. Changes in finance staff and the incomplete status of the District’s general ledger at year-end further contributed to the errors and untimely completion of the SEFA. Effect or Potential Effect: Expenditures of federal awards may be reported incorrectly and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: None noted Context: The Schedule of Expenditures of Federal Awards (SEFA) is a required supplementary schedule for Single Audit reporting and is intended to accurately reflect federal award activity in accordance with Uniform Guidance requirements. During the audit, the District provided an initial SEFA that was not timely and contained material inaccuracies. The re-ported expenditures did not reconcile to the District’s general ledger. Certain programs were incorrectly identified as feder-al rather than state awards, and some federal expenditures exceeded amounts recorded in the accounting records. Because the SEFA was neither complete nor accurate at the time of submission, auditors were required to perform addi-tional procedures to identify errors, investigate discrepancies, and propose audit adjustments. Thei extended the audit timeline and increased the risk of noncompliance with federal reporting requirements. Repeat of a Prior-Year Finding: No Recommendation: The District should strengthen internal controls over SEFA preparation by ensuring the general ledger is finalized prior to preparation, reconciling all reported expenditures to accounting records, and implementing a docu-mented review and approval process to verify accuracy and proper program classification. Strengthening procedures, cross training staff, and implementing supervisory review and approval process to verify accuracy, completeness and proper classification of federal versus state awards will enhance compliance with Uniform Guidance, and reduce the risk of future audit findings, and support a more efficient and timely audit process. District’s Response: The District agrees with the finding and recognizes that staffing changes and an incomplete year-end close contributed to the SEFA issues. The District is strengthening reconciliation, review, and oversight procedures to en-sure timely and accurate SEFA reporting in future years. Corrective Action Plan: The District transitioned to a new accounting software for the year ended June 30, 2026. The new system will allow for more clear tracking of individual federal awardS. that are required to be reported on the Schedule of Expenditures of Federal Awards. Additionally, the new business manager for the 2026-2027 fiscal year has multiple years' experience in preparing Schedules of Expenditures of Federal Awards. Planned Implementation Date: August 1, 2026 Responsible Person: District Finance Director
View Audit 406814
Finding 1223458 (2025-001)
Material Weakness 2025
Parenteral Drug Association, Inc.
PA
Allowable Costs / Cost Principles Cash Management § 200.305 § 200.403
Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cos...
Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cost was incurred for legitimate grant-related purposes within the approved scope of work and period of performance. The expenditure was fully documented, allocable to the award, reasonable in nature, and directly connected to approved programmatic objectives. Management acknowledges that the transaction involved payment for services extending across a future service period. Specifically, 2 CFR 200 does not prohibit recipients from entering into prepaid contractual arrangements for allowable services necessary to support award implementation, particularly where such arrangements reflect standard vendor business practices and operational necessity. Further, the organization’s actions must be evaluated in the context of significant federal payment administration changes that began in February 2025. Historically, the organization received advance funding under the award consistent with the cash management principles contemplated under 2 CFR 200.305. Beginning in 2025, however, the organization was required to operate under a reimbursement-based process requiring submission of supporting documentation prior to payment release. This materially altered the organization’s working capital position and limited its ability to independently finance operational expenditures for extended periods pending reimbursement. As a result, management was required to make operational decisions necessary to ensure continuity of approved grant activities while balancing vendor requirements, cash flow limitations, and evolving federal reimbursement practices. The organization did not receive excess federal cash, improperly retain federal funds, incur unallowable costs, or use award funds outside the approved project scope. The questioned transaction reflects a timing and payment structure issue rather than a violation of fundamental federal compliance requirements. Management also notes that 2 CFR 200.305 expressly contemplates advance payment methodologies and recognizes that reimbursement-only environments may create operational hardships for recipients lacking sufficient working capital. The organization’s actions were undertaken in good faith to maintain uninterrupted program operations under materially changed federal payment conditions. Importantly, the expenditure was allowable, the services supported approved award objectives, the costs were incurred during the award period, supporting documentation exists, no misuse or diversion of federal funds occurred, and no financial harm to the federal government resulted. Note also that going forward, PDA will record future services and subscriptions to prepaid and amortize based on the periods stipulated on the vendor invoices.
View Audit 406813
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